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,-,~ <br />f. ~ ~~~ ~~~~~~~~~~~~~~~~ <br />INTEROFFICE MEMORANDUM <br />TO: KENT <br />FROM: JANET <br />SUBJECT: CCMC <br />DATE: 12/10/' <br />In regazds to your memo dated December 7, 1998 requesting clarification of the two <br />items I noted in my adequacy review memo, dated December 1, 1998. <br />Item No. 1: Collection of vegetation data throughout the liability period. <br />I had noted that there was a permit commitment that the operator would collect <br />vegetative data throughout the liability period. I looked at reclamation reports, <br />looked on the permit shelves for any interim monitoring, looked in the file drawer <br />under the vegetation divider and found no evidence that interim monitoring was <br />performed. At this stage in the liability period, I don't see that it needs to be <br />made a big deal of My main question was, had they collected interim data and if <br />so, where could we find it? If this data exists, it may be useful in showing a <br />steady increase in warm season grass species when we evaluate their data at bound <br />release. If it does not exist, it shouldn't be a big issue. ~,~ aPr~+~7 ~Sh7 -P~(fst <br />Are you aware of the existence of any interim vegetation data? If not, it is a <br />question that could be posed to the operator as, "Was this data collected, when <br />was it submitted to the Division, and in what format? (ARR, sepazate report?) If <br />they did not collect it, they aze not out of compliance with the regulations. They <br />simply did not follow the permit commitment. <br />Item No. 2: Collection of productivity data to determine stocking rates. <br />Once again this question stemmed from a permit commitment. In the logical <br />locations that 1 tried to find the grazing plan, I couldn't find i[. If they have a <br />plan, which they do, and they can reference that they consulted with the local <br />NRCS Range Conservationist on the stocking rates and duration of grazing, which <br />Jerry Koblitz's letter dated Mazch 21, 1996 states, and that is t}re plan they will <br />continue with, then I'm fine with it. You are right that there is no regulatory basis <br />for requiring a grazing plan,just a permit commitment. baS~- <br />If Kaiser Ventures does not plan to graze in 1999, and the Division wil base e <br />post-mining suitability analysis on the vegetation recovery afrer the 1996 grazing, <br /> <br />